Protecting threatened species and ecological communities from invasive species

December 2012

Invasive Species Council PO Box 166, Fairfield, Victoria 3078 Email: [email protected] | Web: www.invasives.org.au The Invasive Species Council campaigns for better laws and policies to protect the Australian environment from weeds, invasive and exotic pathogens. The Invasive Species Council is committed to fostering community participation and activism, supporting our members to have a voice on invasive species issues.

Protecting threatened species and ecological communities from invasive species

Introduction ...... 4 1. Invasive species are a major cause of extinction and threaten about three-quarters of Australia’s threatened species and ecological communities ...... 4 2. As new species arrive and existing invaders increase and spread, the threats of invasive species are increasing...... 5 3. Climate change will exacerbate the threats of invasive species ...... 6 4. Management of invasive species has been ineffective...... 6 5. There is no commitment to the invasive species target in Australia’s Biodiversity Conservation Strategy...... 7 6. Key threatening process provisions are poorly used and ineffective ...... 7 7. There are major legislative gaps in regulating actions involving invasive species within Australia ...... 10 8. Resources for invasive species management are woefully inadequate ...... 11 9. A proposal for Environment Health Australia ...... 13 Appendix 1. State of the Environment 2011 – verdict on invasive species ...... 15 Appendix 2. Yellow crazy ants ...... 15 Appendix 3. The cost of saving the Kimberley’s wildlife ...... 17 Appendix 3. What weeds do ...... 18

Introduction Conservation Strategy – to reduce invasive species impacts on threatened biodiversity by 10%. There has been no feasibility assessment, no baseline To properly document the threats of invasive species and the ways in which current assessment and no costed plan for implementation, rendering the target merely laws, policies and programs are failing to protect threatened species and ecological aspirational and destined to fail. communities from invasive species would require a substantial treatise. We provide here only a brief summation and a few case studies to exemplify major gaps in our national capacity to protect threatened biodiversity from invasive species. We address four terms of reference: 1. Invasive species are a major cause of extinction and threaten about three-quarters of Australia’s (a) key threats to listed species and ecological communities; threatened species and ecological communities (d) regulatory and funding arrangements at all levels of government; Australia has suffered dozens of extinctions due largely to invasive species, (e) timeliness and risk management within the listings processes; including the most recent just three years ago – the Christmas Island pipistrelle. (f) the historical record of state and territory governments on these matters We lead the world in mammal extinctions due mainly to invasive predators, and many more mammals are on the brink, including in northern Australia previously Invasive species impacts warrant a substantial focus by the inquiry for the following thought to be secure because of low levels of habitat loss.1 More than 70% of 1700 reasons: species listed as nationally threatened and more than 80% of listed ecological • Invasive species are one of the four major threats to biodiversity (the communities are imperilled by introduced animals, plants or diseases. The extent of others being land clearing, damaging fire regimes and climate change) and threat is poorly documented and is probably worse than documented. interact synergistically with other major threats such as climate change and Extinctions due substantially to invasive species include: fire. • 25 mammals (19 species, 6 subspecies), probably mostly due to , • Invasive species impacts are increasing, and many more extinctions are foxes, rabbits likely unless there is a greater commitment by Australian governments to prevention, eradication, containment and control of invasive species. • 13 island (3 species, 10 subspecies) due mainly to rats, cats and pigs • There are major gaps in legislation, policy and programs, at federal and • 4 frogs due to chytrid fungus state/territory level, which can be addressed to abate threats. • 4 plants due to weeds Our main message to the inquiry is the need for a more business-like, fair dinkum Invasive species threats to listed species and ecological communities: approach to invasive species threats – to identify long-term goals and targets that reflect the immense intrinsic and instrumental values of Australia’s species and • Invasive plants and animals threaten 61% of nationally listed threatened ecological communities; develop costed plans for prioritised, realistic goals; close species 2 major gaps in legislation and policy; and properly and productively involve the 3 • Diseases (mostly exotic) threaten 15% of listed threatened species community sector in policy-setting, decision-making and on-ground conservation. The current approach to conserving Australia’s species and ecological communities is the opposite of business-like. Environmental goals are often not taken seriously, 1 Fitzsimons J, Legge S, Traill B, Woinarski J. 2010. Into Oblivion? The Disappearing Native are almost never met, and failures have no consequences for those in charge. A Mammals of Northern Australia. The Nature Conservancy: Melbourne. prime example of this is the invasive species target of Australia’s Biodiversity 2 Evans M, Watson J, Fuller R, Venter O, Bennett S, Marsack P, Possingham H. 2011. The spatial distribution of threats to species in Australia. BioScience 61: 281-289.

• Invasive species threaten >80% of nationally listed ecological communities 2. As new species arrive and existing invaders Weeds have caused few extinctions but are a major contributor to threat increase and spread, the threats of invasive species syndromes and degradation. They can dominate landscapes - In NSW, for example, weeds account for 52 (43%) of the 120 most widely distributed plant are increasing. 4 species – and compromise ecological processes such as fire and nutrient cycles. The State of the Environment 2011 reported that invasive species impacts on See Appendix 4 for an outline of weed impacts. biodiversity were deteriorating. See Appendix 1 for a more detailed summary of the Australia ranks globally as one of the worst affected countries in terms of numbers State of the Environment findings. The deteriorating trend is due to an accelerating of invasive species and the ecological damage sustained. There is considerable rate of new invaders (such as myrtle rust and Asian honeybees) and the spread of government rhetoric about Australia’s “enviable biosecurity system” and our relative already established species. freedom from major pests and diseases. While our agricultural industries enjoy The majority of introduced species already in Australia are yet to achieve the full trade advantages due to freedom from many of the world’s most damaging pests extent of their potential spread and density: and diseases, there is nothing enviable about our record on environmental biosecurity.5 Contrary to the claim in the guide to the Quarantine Proclamation Australia is in the throes of ecological upheaval, and most of this change is coming 1998 that ‘Australians generally benefit from a natural environment that, compared … from old pests tightening their grip on the land. It is important to understand that most pests in Australia have yet to occupy their full range: they are still migrating to other countries, is relatively free of many debilitating pests and diseases of 11 humans, animals and plants’,6 Australia is actually a world leader in the extent of outwards or increasing in density (infilling) or both. invasive species threats to the environment. As well as having the highest number Trends are also deteriorating because of the increasing vulnerability of native of mammal extinctions and declines due to invasive species, we have the highest species and ecosystems due to multiple other threats – climate change, habitat 7 number of invasive trees and shrubs (29% of the global total), the highest or loss and fire. For example, damaging fire regimes in northern Australia increase the 8 second highest number of naturalised plant species, and one of the highest vulnerability of small mammals to predation due to loss of shelter. densities of weeds9 and extent of widespread weeds.10

3 Ibid. 4 Stohlgren T, Pysek P, Kartesz J, et al. 2011. Widespread plant species: natives versus aliens in our changing world. Biological Invasions 13:1931–1944. Of 13 regions, NSW was second highest after North America, where aliens accounted for 51.3% of the 120 most widely distributed plant species. 5 As one rough indicator, Australia has more than half the species in a List of 100 of the Simberloff D, Souza L, Nunez M, Barrios N, Bunn W. 2012. The natives are restless, but not World's Worst Invasive Alien Species, not including the several which are Australian natives often and mostly when disturbed. Ecology 93:598-607. According to the latter, the US has < (see Global Invasive Species Database at 3000 naturalised plant species, fewer than Australia. http://www.issg.org/database/species/search.asp?st=100ss&fr=1&str=&lang=EN) 9 6 Vitousek P, D’Antonio C, Loope L, Rejmanek M, Westbrooks R. 1997.‘Introduced Species: A significant component of human-caused global change’. New Zealand Journal of Ecology 7 Richardson D, Rejmánek M. 2011. Trees and shrubs as invasive alien species – a global (21) 1-16. Third to New Zealand and Coterminus US, but more recent information suggests review. Diversity and Distributions 17: 788-809. Australia has a higher density than the US. 8 Vitousek P, D’Antonio C, Loope L, Rejmanek M, Westbrooks R. 1997.‘Introduced Species: 10 Stohlgren T, Pysek P, Kartesz J, et al. 2011. Widespread plant species: natives versus A significant component of human-caused global change’. New Zealand Journal of Ecology aliens in our changing world. Biological Invasions 13:1931–1944. (21) 1-16. 11 Low T. 1999. Feral Future: The Untold Story of Australia’s Exotic Invaders. Penguin.

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possums, which eat them, to forage more widely. This makes them more 3. Climate change will exacerbate the threats of 16 vulnerable to predation by foxes, which also eat bogong moths. Feral cats may invasive species be able to spread to some islands currently too wet for them now and which serve 17 As recognised in the 2009 assessment of the vulnerability of Australia’s biodiversity as sanctuaries from exotic predators. Exotic pasture grasses in northern Australia to climate change commissioned by the Federal Government, in many cases the up to 4 metres tall (eg. gamba grass Andropogon gayanus) fuel fires so intense they can kill trees. In a damaging cycle that can turn native woodlands into exotic biodiversity impacts of invasive species benefiting from climate change are likely to 18 12 exceed the direct impacts of climate change. This is because: grasslands, such fires promote yet more grass invasion. Climate change could increase the frequency of fires, facilitating the further invasion of exotic grasses. • many invasive species are highly adaptable, tolerant of a wide range of Many more examples are provided in a recent submission to the Inquiry into climatic conditions and advantaged by disturbance; Australia’s biodiversity in a changing climate by the House Standing Committee on 19 • extreme events often facilitate biological invasions; Climate Change, Environment and the Arts.

• native species under stress due to climate change are less competitive with and more vulnerable to harm by invasive species; and 4. Management of invasive species has been • human responses to climate change are likely to provide more invasive opportunities and may result in less effective control. ineffective For example, in Southwest Western Australia, where dieback caused by Australia’s most recent State of the Environment report (2011) gave the worst Phytophthora cinnamomi has infected a million hectares of native bush, threatening possible ratings for invasive species impacts on biodiversity: “very high” and 13 dozens of endemic species, climate change is expected to bring more rain during “deteriorating” and found that management outcomes and outputs are “ineffective” summer, which would spread the disease more rapidly because the spores travel (see Appendix 1). One of many critical comments was that: with flowing rainwater. This could result in plant extinctions and ecosystem 14 Government responses to invasive species are uncoordinated at the collapse. The disease could also worsen in south-eastern Australia if there are 15 national level, reactive, focused on larger animals, biased towards potential wetter summers and warmer winters under climate change. Foxes are already impact on primary industry at the expense of the total ecosystem, and increasing their numbers at higher altitudes in the Australian Alps as the climate critically under-resourced. warms. Bogong moths are arriving later, forcing endangered mountain pygmy

16 Low T. 2008. Climate Change and Invasive Species: A Review of Interactions (Canberra, 12 Steffen W, Burbidge A, Hughes L. et al. 2009. Australia's Biodiversity and Climate Biological Diversity Advisory Committee). Change: A strategic assessment of the vulnerability of Australia's biodiversity to climate 17 Steffen W, Burbidge A, Hughes L. et al. 2009. Australia's Biodiversity and Climate change. Technical synthesis of a report to the Natural Resource Management Ministerial Change: A strategic assessment of the vulnerability of Australia's biodiversity to climate Council commissioned by the Australian Government (Canberra, Department of Climate change. Technical synthesis of a report to the Natural Resource Management Ministerial Change). Council commissioned by the Australian Government (Canberra, Department of Climate 13 Cahill D, Rookes J, Wilson B, Gibson L, McDougall K. 2008. Phytophthora cinnamoni and Change). Australia's biodiversity: impacts, predictions and progress towards control, Australian Journal 18 Rossiter N, Douglas M, Setterfield S, Hutley L. 2003. Testing the grass-fire cycle: Alien of Botany 56: 279-310. grass invasion in the tropical savannas of northern Australia. Diversity and Distributions 9: 14 Invasive Species Council. 2009. Killer plant disease could devastate WA biodiversity 169-176. hotspots. Double Trouble Ebulletin Edition 1 (February 2009). 19 See 15 Department of Sustainability and Environment 2008. Victoria's public land Phytophthora http://www.aph.gov.au/Parliamentary_Business/Committees/House_of_Representatives_Co cinnamomi management strategy. (Victorian Government). mmittees?url=ccea/ccbio/subs/sub060.pdf

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To stabilise and reduce environmental impacts of invasive species will require threatened species and ecological communities is conducted, and much of the addressing multiple weaknesses in Australia’s biosecurity system, including major information in conservation advices is based on coarse expert estimates of gaps in law and policy, and inadequate surveillance, eradication and control impacts. The only baseline information available is the number of threatened programs. Due to a lack of time, we highlight flaws in just four areas: (a) the species and ecological communities threatened by invasive species, which does Biodiversity Conservation Strategy 2010-2030, (b) provisions under the EPBC Act not reflect the reality of current impacts on threatened biodiversity because of the for key threatening processes, (c) legislative gaps and (d) funding. substantial numbers of threatened species and ecological communities that are not listed.20 Halfway to the target deadline, there is no implementation plan and no

identification of costs. The latest state of the environment assessment found that trends were deteriorating. Long-established threats are increasing – feral cats in 5. There is no commitment to the invasive species northern Australia, , Phytophthora cinnamomi in southwest Australia, feral goats in target in Australia’s Biodiversity Conservation semi-arid areas, weeds virtually everywhere, for example – and new threats are emerging – foxes in Tasmania, feral deer in many new locations, myrtle rust in Strategy eastern Australia, yellow crazy ants in the Wet Tropics (see Appendix 2) Target 7 of the Biodiversity Conservation Strategy 2010-2030 is: Recommendation: By 2015, reduce by at least 10% the impacts of invasive species on • Commission an assessment of the measures and funding necessary to threatened species and ecological communities in terrestrial, aquatic and achieve the invasive species target in the National Biodiversity Conservation marine environments. Strategy, and develop a costed plan to do so. On its release the federal Environment Minister contended that Australia was ‘one of very few countries to have committed to national measurable targets for biodiversity conservation.’ But the invasive species target is almost as bad as not having any target and there is no evidence of commitment to it. Seemingly plucked 6. Key threatening process provisions are poorly used out of the air, it is unrealistic and therefore likely to be ignored. ISC has been told and ineffective by federal environment officers that it should be regarded as ‘aspirational’. This whimsical approach to one of the greatest threats to the continued existence of The capacity under the EPBC Act to declare key threatening processes (KTPs) and numerous species in Australia would not be tolerated for issues in other areas of develop threat abatement plans (TAPs) has potential to be a major tool for government. addressing abating invasive species threats but is currently failing to deliver. The provisions recognise that many processes threaten multiple species and that it is The government department charged with much of the responsibility for necessary to take a national approach. A process is a ‘threatening process’ if “it environmental biosecurity, Department of Agriculture, Forestry and Fisheries, does threatens, or may threaten, the survival, abundance or evolutionary development of not embrace the Biodiversity Conservation Strategy target for invasive species and a native species or ecological community”.21 has no specific plan to meet it. With regular breaches of quarantine resulting in the establishment of biodiversity-threatening organisms – myrtle rust, Asian honeybees The KTP provisions could be particularly useful for invasive species because of the and yellow crazy ants being recent examples – achieving the target relies on DAFF wide variety of threat pathways, jurisdictions and sectors involved in threatening giving sufficient priority to environmental threats. The at least 30 breaches that processes, and the lack of simple legislative means of addressing such landscape- have resulted in yellow crazy ant infestations in Queensland suggest there has been a lack of focus on this very high environmental threat (see Appendix 2). 20 Evans M, Watson J, Fuller R, Venter O, Bennett S, Marsack P, Possingham H. 2011. The It is not clear what the strategy target implies as there is no quantitative information spatial distribution of threats to species in Australia. BioScience 61: 281-289. about invasive species impacts on threatened biodiversity. Very little monitoring of 21 Environment Protection and Biodiversity Conservation Act 1999 s 188(3).

A submission regarding the effectiveness of threatened species and ecological communities’ protection in Australia - 7 scale threats. A majority of KTP listings are for invasive species (13 of 19), but they a KTP (two current assessments are due to take three years.24) It then takes an are underused, underfunded and lack effective mechanisms for abating invasive average 3.7 years to develop a threat abatement plan.25 On average, therefore, it threats. takes six years to assess a KTP and develop a TAP. The business sector would be thumping political tables (and taking out full-page Key threatening processes listed under the EPBC Act media advertisements) if it took this long to get their applications assessed. Applications for environmental destruction whizz through in comparison to nominations for threat abatement (and also threatened species and ecological Type of KTP Listed KTP (abbreviated) Date listed TAP communities). Rabbits 2000 2008 Process deficiencies: The process of assessment is lacking in transparency. Feral goats 2000 2008 Nominations are rejected despite meeting the criteria under the EPBC Act. In the Red foxes 2000 2008 Introduced past four years, ISC has made two nominations (for the invasive pasture grass, tall Feral cats 2000 2008 vertebrates wheatgrass, and for feral deer) both of which amply met the criteria, with evidence Exotic rats on offshore islands 2006 2009 for threats to 28 and 18 species or ecological communities respectively, which were Cane toads 2005 2011 rejected for reasons outside the criteria in the EPBC Act. Feral pigs 2001 2005 Yellow crazy ants (Anoplolepis gracilipes) on 2005 2006 Introduced Christmas Island A process is eligible to be listed as a ‘key threatening process’ if: invertebrates Red imported fire ant, Solenopsis invicta 2003 2006 • It could cause a native species or an ecological community to become eligible Introduced 5 invasive pasture grasses in northern Australia 2009 2012 for listing as extinct, extinct in the wild, critically endangered, endangered or plants Escaped garden plants 2010 No TAP 22 vulnerable; Introduced Root-rot fungus (Phytophthora cinnamomi) 2000 2001 pathogens Chytridiomycosis (chytrid fungus) 2002 2006 • It could cause a listed threatened species / ecological community to become Coastal otter trawling – turtle bycatch 2001 No TAP eligible to be listed in another category representing a higher degree of Oceanic longline fishing – seabird bycatch 2000 2006 endangerment; or Marine debris impacts on vertebrate marine life 2003 2009 Others • It adversely affects 2 or more listed threatened species / ecological Land clearance 2001 No TAP communities. Anthropogenic climate change 2001 No TAP Psittacine circoviral (beak and feather ) disease 2001 2005

Making a nomination is demanding, often requiring several weeks work to compile There are many more major threats that warrant KTP listing but in the past decade the evidence required. Yet, ISC’s experience is that nominations are rejected for no just seven new KTPs have been listed (six have been for invasive species). legislatively valid reason and typically with no reasons provided (again, note the Time taken: Currently, the environment department has sufficient resources to 23 assess only one KTP nomination a year. It takes an average 1.8 years to assess 23 Senate Standing Committee on Environment and Communications Legislation Committee Answers to questions on notice Sustainability, Environment, Water, Population and Communities portfolio Additional Budget Estimates, February 2012 24 Artificial watering points was nominated in 2009 and assessment was due in Sept 2012; 22 The Senate disallowed an inadequate 2009 TAP, so another has been under development noisy miners was nominated in 2011 and assessment is due in Sept 2014. for the past 3 years. 25 Ibid.

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difference in approach taken to assessments of destructive development). Either develop a TAP, as well as taking an average of close to four years to develop, they the current approach to KTP listing decisions is ad hoc or they are based on non- are often poorly implemented. There is no regular review of progress made on legislative, non-public criteria such as whether there are funds available for goals and actions and TAPs are often left to languish long after their intended 5 assessment. The invitation for the public to make nominations based on the year review date – presumably due to a lack of resources (there are currently legislative criteria is misleading. Under the current opaque and underfunded seven TAPs > 5 years old). In most plans there is very little community involvement arrangements, ISC won’t make any further nominations because it has been a except through a formal consultation process. waste of scarce community time and resources. There should be a much more Threat abatement plans only bind the Commonwealth and Commonwealth systematic approach to KTP listings to ensure that the major threats requiring agencies - States and Territories are not required to cooperate – and there is no national focus are recognised and acted on. guarantee of any of the TAP actions being implemented. For invasive species Novel biota KTP listing: It appears that there has been some move to more TAPs, they often depend on inadequate state and territory listing processes and systematic listings by an internal nomination to list ‘novel biota’ as a KTP, a listing competitive short-term, project-specific grants programs. There is no TAP-specific that has been in train for at least two years. However, this all-encompassing listing funding stream and no guaranteed funding for any TAP priorities. is apparently the reason for rejection of for ISC nominations of more specific Linking to regulation: There should be federal regulatory mechanisms where this is invasive threats on the basis that they can be included as examples in the novel 26 a feasible way to mitigate key threatening processes. The federal government has biota listing. Ironically, the more systematic listing is being used to preclude the capacity under the EPBC Act to regulate harmful activities involving invasive meaningful threat abatement action on specific threats such as feral deer species. species but chooses not to use it. Section 301A of the EPBC Act provides for the There is no point developing a threat abatement plan for such a broad threat establishment of a list of species, other than native species, that do, may, or would category as novel biota (encompassing invasive plants, animals, pathogens) and be likely to threaten biodiversity in Australia. Those species may be regulated or the draft nomination recommends against this. A similar fate – recognition but no prohibited from being brought into Australia, or from being traded in various ways. action – has already befallen the escaped garden plant KTP listing. Likewise, the This provision could be used to address in part the threats of several of the listed land clearing and anthropogenic climate change KTP listings have no practical KTPs, in particular escaped nursery plants. conservation benefit. Escaped nursery plants were listed as a key threatening process under the EPBC ISC opposes the intention to list novel biota as an all-embracing invasive species Act but this has no practical effect in preventing the sale of unsafe plants. No TAP KTP if it is to preclude the listing of more specific invasive species threats and the was developed and threat abatement relies in large part on individual states and preparation of threat abatement plans for specific threats. We recommend the territories declaring individual species after drawn-out assessment processes. novel biota listing be used as the parent listing for multiple KTP sub-listings and as Trade in the majority of unsafe nursery plants remains unregulated in most state the basis for systematically addressing gaps in abatement of invasive species and territory jurisdictions. threats to biodiversity. Compare the approach taken to environmentally harmful chemicals. If chemicals Threat Abatement Plans: The only real value of KTP listings comes from the are assessed as a threat to human or environmental health, the Australian development and implementation of TAPs, which outline the research, Pesticides and Veterinary Medicines Authority can ban their sale or regulate how management and other actions needed to protect native species and ecological they are used. Nationally significant threats to the environment caused by invasive communities from the listed threat. When the Environment Minister does agree to species warrant a similar national regulatory capacity. Just as chemicals are systematically assessed, so should key threatening processes be comprehensively listed and threat abatement plans prepared. 26 The Environment Department has advised the Invasive Species Council that the Threatened Species Scientific Committee, which assesses nominations and has developed There is a need to integrate key threatening process listings with other the Novel Biota nomination, intends it to capture all invasive species and ‘avoid the need to environmental programs, to ensure they are used to optimal effect and are funded. assess and list every invasive species individually’.

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For example, TAPs for significant invasive species should play a major role in • Use the proposed ‘novel biota’ Key Threatening Process listing as the basis for Australia’s biodiversity conservation strategy to reduce the impacts of invasive developing on a prioritised basis multiple Threat Abatement Plans to address species. invasive species threats where these plans provide a feasible way to address threats. Ensure that the novel biota listing does not preclude listing of more Proposed changes to the KTP provisions: The Federal Government plans to make specific invasive species threats. KTP listings and TAPs more flexible on the basis of a recommendation made by the Hawke review of the EPBC Act. It is proposed to undertake regional threat • Publish all criteria and reasons for listing priorities and for listing decisions. abatement plans, and to expand the definition of ‘key threatening processes’ to Priorities should be determined by the Threatened Species Scientific include both immediate and longer-term threats to Australia’s national Committee, not the Minister. environmental assets. These would be positive reforms if there were sufficient • resources for assessing and listing KTPs and developing and implementing TAPs. Undertake a review of the effectiveness of Threat Abatement Plans over the But they will be pointless unless the dire funding shortage for assessments, listings, past decade, assessing the extent to which actions have been implemented planning and implementation is addressed and unless there is a commitment by and the goals achieved. relevant governments to implement the TAPs. There needs to be a much clearer • Use section 301A of the EPBC Act to regulate actions involving invasive accounting of implementation with regular reporting on progress to achieve priority species Key Threatening Processes where this will contribute to achieving outcomes. threat abatement. More flexible KTP and TAP arrangements would permit more rapid research and • Provide costings in Threat Abatement Plans for priority actions and identify management response to emerging threats, such as recent incursions of myrtle funding options. Ensure that criteria for funding priorities under Caring for our rust, Asian honeybees, and pigeon paramyxovirus. Country include implementing Threat Abatement Plans. The NSW Scientific Committee, which conducts KTP and threatened species • Develop an agreement through COAG about requiring implementation by all assessments for NSW, made several recommendations about the federal listing governments of high priority actions of Threat Abatement Plans – through process during the Hawke review, which unfortunately were not adopted. These enabling legislation – to ensure that just as there is a requirement of included making the federal Threatened Species Scientific Committee a statutory governments to assess developments there is also a requirement to abate high authority with power to make determinative listing decisions rather than simply priority threats. advising the Minister, making the Committee functionally independent of the Minister and Department, publishing the criteria and reasons for priorities and • Make the Threatened Species Scientific Committee a statutory authority with having priorities determined by the Committee rather than the Minister. Specific to power to make determinative listing decisions. KTPs, the NSW Scientific Committee recommended that under-representation of particular types of threat be redressed. We endorse all these recommendations. Recommendations: 7. There are major legislative gaps in regulating • Provide sufficient funding for assessment of Key Threatening Processes and actions involving invasive species within Australia development of Threat Abatement Plans. Although the release of an invasive plant or in a new area could have a • Undertake systematic listing of Key Threatening Processes to properly reflect much greater impact on biodiversity than particular mines or residential the threats to biodiversity and develop Threat Abatement Plans on a prioritised developments, there is no clear mechanism under the EPBC Act for assessing this. basis. The Act requires the assessment of invasion risks due to imports of new animal taxa (mostly at a species level) into Australia while plants are assessed under the Quarantine Act 1908 but there is no direct trigger for assessment of releases, trade

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in or use of invasive species or potential invasive species within Australia. Only two way: relying on each state and territory to individually reform will not work, as has proposed agricultural uses of invasive plants have been referred for assessment been demonstrated by the many years of failure to do so. under the EPBC Act (as far as we know). Nor are such actions generally assessed New biosecurity legislation has just been introduced to Federal Parliament – the under most state and territory legislation. There tends to be a major bias in Biosecurity Bill 2012. It does not address the post-border gaps noted above. regulation towards specific, site-focused impacts rather than the landscape-scale Although the Bill will provide the basis for many improvements in biosecurity, such threats represented by many invasive species as well as other threats such as fire as national regulation of ballast water, it has many flaws that ISC and other regimes. 28 environment groups have identified. As it is the subject of a separate inquiry, we The Hawke review of the EPBC Act found that most states and territories are failing won’t address it here. to prevent the deliberate movement of thousands of exotic plant species, many of Recommendation: which are known invaders and the majority of which have never been assessed for their weed risk. Of the ~30,000 exotic plant species in Australia, about 10% have • Use s301A of the EPBC Act to implement a science-based, cost-effective already established in the wild; another 6000 are weedy overseas and therefore national approach to restrict the movement and sale of introduced species likely to become weeds in Australia. Apart from Western Australia, which takes a within Australia unless they pass a risk assessment. ‘white list’ approach to exotic plant species, there are no restrictions on the sale and movement of more than 98% of exotic plant species in most parts of Australia. For example, of 340 ranked environmental weeds in NSW,27 about 90% can be sold or planted in part or all of NSW. Almost half (44%) are permitted imports, 8. Resources for invasive species management are allowing for continued introduction of new genetic material from overseas. From woefully inadequate 2000-2010, new cultivars for at least 17 (5%) were registered as new plant breeds There is widespread agreement that current funding levels and approaches are far in Australia. from sufficient to halt and reduce the threat of invasive species to biodiversity. New Given the already huge impacts of weeds, this lack of basic precautions is a major Zealand researchers have estimated that an extra 9 to 25-fold funding is required in 29 biosecurity and environmental failing, as the Hawke review found: that country to address the threat of invasive species to biodiversity. They comment, and we share their opinion, that a similar increase is probably required in Movement of established, potentially damaging exotic species between Australia. That no such assessment has been undertaken for Australia is indicative States and Territories represents a substantial failure of State and of the ad hoc and short-term approach taken to invasive species management for ‐ Territory based environmental regulation. Development of national the environment. protocols, in cooperation with the States and Territories, for assessing resident, potentially damaging exotic species, and for designing and Australia has been a world leader in protecting agricultural assets from invasive implementing criteria to manage their movement within Australia, may be a species, and strategies and priorities are generally informed by a sound knowledge useful first step towards remedying this situation (Hawke Review, 6.43). of threats, the impacts of invasion and the costs of management. For example, on The Federal Government already has the legal capacity s301A of the EPBC Act to regulate trade and use of damaging introduced species. There is no other feasible

28 See http://www.invasives.org.au/documents/file/sub_draft_biobill_2012.pdf for ISC’s submission. 27 Downey P, Scanlon T, Hosking J. 2010. Prioritising alien plant species based on their 29 Choquenot D, Clout M. 2011. Another inconvenient truth: How much pest control will it ability to impact on biodiversity: a case study from New South Wales. Plant Protection take to halt the decline in biodiversity? Security from the impact of vertebrate pest Quarterly 25(3): 111-26. animals.15th Australasian Vertebrate Pest Conference. Sydney.

A submission regarding the effectiveness of threatened species and ecological communities’ protection in Australia - 11 foot and mouth disease, the Department of Agriculture, Fisheries and Forestry Unlike incursions that impact on primary production, where active says: 30 engagement by business is motivated by self-protection, the effort required to respond to an incursion affecting the environment must be provided ‘The Australian Government has committed to invest more than half a primarily by governments. billion dollars to prepare for and manage the [foot and mouth disease] threat… Australia has in place detailed contingency plans and a There needs to be substantial long-term investment to bring environmental comprehensive whole-of-government approach to managing animal health biosecurity functions at least up to par with those for primary industries. Recently, emergencies that are designed to ensure that resources from a wide range the Queensland Government abandoned the eradication program for yellow crazy of agencies are available.’ ants, recognised globally one of the major threats to biodiversity and regarded by the Wet Tropics Management Authority as likely to be ‘an absolute disaster for Environmental biosecurity currently lags far behind agricultural biosecurity and biodiversity’ in the Wet Tropics (see Appendix 2). If it were a major industry threat, there is nowhere near an equivalent understanding of threats, impacts and costs, the Queensland Government would undoubtedly fund eradication. Environmental as recognised in the 2009 Hawke review of the EPBC Act. programs have been abandoned in favour of agricultural priorities. This is a Environmental biosecurity issues have not traditionally received the same common problem – when budgets are tightened, environmental biosecurity attention as the potential impacts of pathogens, diseases, weeds or pests programs tend to go first. on primary production. … The new biosecurity legislation should require To achieve environmental goals will require much greater community contribution, that the environment must be given equal consideration alongside human including much greater involvement of the community and environmental sector in health and economic and social considerations…. development of biosecurity policy and implementation. There needs to be reform of Although environmental biosecurity is more challenging than that for industry – with community engagement processes to bring them up to at least the standard of more threats, more species at risk, more stakeholders, and less knowledge – more those for industry bodies. For several years, the federal and state/territory public resources are dedicated to protecting industries than the environment from governments have jointly contributed two-thirds of the operational funding for Plant invasive species. For most of its history, our biosecurity system has been directed Health Australia and Animal Health Australia to develop contingency plans and primarily at protecting agriculture from invasive species. Current biosecurity strategies for high priority industry threats. This has been an excellent model for arrangements have not been designed from an ecological perspective. improving industry biosecurity. ISC has proposed an equivalent body for environmental biosecurity (see below). The community relies on governments to invest resources on their behalf to protect the environment for the public good. There needs to be more equity for the To meet the national biodiversity conservation strategy target will require research environment in public resources dedicated to biosecurity, as recognised by the directed to the highest priority research questions. The level of federal government Beale review: funding dedicated to environmental biosecurity research is dwarfed by that dedicated to industry research. We commend the government for its commitment to ‘…Australia has a relatively poor knowledge of the biosecurity threats to its match dollar-for-dollar industry funds to rural development corporations, a natural environment. This is largely a function of the absence of substantial proportion of which is devoted to biosecurity issues. However, the need commercial incentives to research and monitor environmental pests and for research funding in environmental biosecurity is even greater than that for diseases. As a result, the principal responsibility for biosecurity research as industry biosecurity – with more species impacted, more invasive threats and less it relates to the natural environment lies with governments and the knowledge – and the public good rationale for funding is more compelling. In the community. These activities have not received a high priority for funding. short-term, the government should fund environmental biosecurity research to a level at least equivalent to that for industry biosecurity research.

30 Appendix 3 provides an example of the sort of ‘getting down to business’ approach See DAFF website at http://www.daff.gov.au/animal-plant-health/pests-diseases- desperately needed for conservation. A group of researchers last year assessed weeds/animal/fmd.

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31 the feasibility and cost of saving wildlife in the Kimberley. The optimal investment • Improve Australia’s biosecurity preparedness: Eg. Develop biosecurity – sufficient to maintain 45 at-risk species over the next 20 years – amounts to plans for high-risk potential environmental invaders, and surveillance about $40 million a year after set up costs of $95 million. Much of it would go to protocols for environmental incursions, undertake foresighting and keeping invasive species at bay. With costs and feasibilities set out, there is now a reporting to identify emerging and future threats, and develop strategies to ‘business case’ for investing in the future of Kimberley wildlife, and much less limit the exacerbation of invasive species impacts under climate change. excuse for governments to avoid doing so. • Promote effective responses to environmental incursions: Eg. Participate in Recommendation: National Environmental Biosecurity Response Agreement processes and commission, co-ordinate, facilitate and manage nationally agreed • Commission assessments of the measures and funding required and funding options to achieve high priority biodiversity goals, as exemplified in environmental health and biosecurity projects, and lead preparation of AusEnvPlans to establish detailed emergency response arrangements the report ‘ Priority threat management to protect Kimberley wildlife.’ under NEBRA.

• Enhance community awareness, vigilance and action in biosecurity: Eg. Build public awareness of environmental biosecurity and support the 9. A proposal for Environment Health Australia community to become involved in biosecurity policy development and Australia urgently needs a more ecological, coordinated and collaborative approach implementation, develop best practice communication and community to environmental biosecurity. Invasive species are overwhelming the capacity of activation approaches in environmental biosecurity, and harness the current biosecurity systems, as acknowledged in the State of the Environment support of foundations and NGOs. 2011. The complexity and scale of environmental challenges warrants a • Improve environmental biosecurity capacity – knowledge, people and comprehensive biosecurity focus facilitated by a new national body to engender a resources: Eg. Facilitate governments, community groups and researchers genuine partnership approach between governments, communities and relevant to work together to improve environmental health in Australia, identify high industries. It will not be sufficient to bolt on environmental responsibilities to existing priority research needs for environmental biosecurity, and identify and structures and cultures. prioritise invasive species management actions which can be implemented Environment NGOs propose the establishment of a national body, Environment to deliver development and carbon offsets. Health Australia, that brings together major participants in environmental • Improve coordination and collaboration between jurisdictions, agencies and biosecurity, effectively involves the community sector, and facilitates a cross- sectors: Eg. Collaborate with industry biosecurity bodies to jointly develop jurisdictional, cross-sector collaboration to achieve much stronger environmental biosecurity responses where invaders have both environmental and biosecurity. It would be the environmental equivalent of, and collaborate with, industry impacts, and conduct joint research projects. Animal Health Australia and Plant Health Australia. • Monitor and report on Australia’s progress in environmental biosecurity: Proposed functions Eg. Develop indicators for monitoring progress on meeting environmental • Create strong environmental biosecurity foundations: Eg. Develop and biosecurity targets, and monitor and report on the establishment, spread promote more ecologically informed approaches to protect species, and containment of ecologically important invasive species. ecological communities and ecological processes from invasive species Proposed membership Environment Health Australia would be structured to foster partnerships between 31 major participants and stakeholders in environmental biosecurity and promote Carwardine J, O’Connor T, Legge S, Mackey B, Possingham H, Martin T. 2011. Priority collaboration with industry bodies where there are shared interests. One potential threat management to protect Kimberley wildlife. CSIRO Ecosystem Sciences, Brisbane.

A submission regarding the effectiveness of threatened species and ecological communities’ protection in Australia - 13 model is that of Plant Health Australia and Animal Health Australia. Potential members include: • Federal Government: environment and biosecurity agencies • State/Territory Governments: environment and biosecurity agencies • Environmental NGOs with an environmental biosecurity focus • Indigenous land management organizations • NRM and conservation land management organisations • Research institutions focused on biosecurity, ecology and environmental management • Professional bodies for people involved in environmental biosecurity • Environmental and allied primary production industry bodies. A more detailed proposal for Environment Health Australia is attached and can be downloaded from http://www.invasives.org.au/page.php?nameIdentifier=environmenthealthaustralia. Recommendation: • Establish an environmental biosecurity organisation, Environment Health Australia, to drive cross-jurisdictional and cross-sectoral collaboration.

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On information: State of environment reports by states and territories ‘mostly list Appendix 1. State of the Environment 2011 – verdict on plans, strategies and inputs to management, but rarely report on the effectiveness invasive species32 of processes or on outputs and outcomes’ for invasive species. The Assessment of Australia’s terrestrial biodiversity 2008 is quoted: ‘The scale of the impacts from The report card assessments on invasive species were bleak: high to very high [invasive species] is such that the voluntary and uncoordinated approaches impacts of invasive species with deteriorating or unclear trends. Impacts on adopted to date will not be effective.’ biodiversity and management outcomes received the worst possible ratings. Environment Degree of Trend Management component impact effectiveness – outputs & outcomes Appendix 2. Yellow crazy ants33 Biodiversity Very high Deteriorating Ineffective As part of their recent cost cutting, the Queensland Government has abandoned an Heritage values Very high Deteriorating NA eradication program for invasive yellow crazy ants (Anoplolepis gracilipes).34 The decision was made solely on financial grounds – that the existing small allocation Inland water High Deteriorating Partially effective was insufficient to achieve eradication. Other environmental programs have also environments lost funding. This is a constant problem in biosecurity across Australia – when Land environment High Deteriorating Partially effective budgets are cut, the environmental programs go first. At the same time, the government has substantially increased funding for wild dog control, a program for Antarctic terrestrial High Unclear Effective the commercial benefit of graziers, and is pouring considerable resources into environment 35 eradicating Bovine Johne's disease from cattle in Queensland. Yellow crazy ants fit the stereotype of a rapacious marauding invader. On The report notes deficiencies of management, information and resources for Christmas Island, they have killed tens of millions of the iconic (and ecologically invasive species, for example: important) red crabs, as well as robber crabs. Prior to a multi-million dollar baiting program, they had invaded more than a quarter of the island’s rainforest, reaching On management: ‘Government responses to invasive species are uncoordinated at densities of more than 2000 foraging ants a square metre and transforming the the national level, reactive, focused on larger animals, biased towards potential impact on primary industry at the expense of the total ecosystem, and critically under-resourced.’ 33 Abbott K. 2005. Supercolonies of the invasive yellow crazy ant, Anoplolepis gracilipes, on On resources: ‘Most jurisdictions admit they are unable to provide sufficient an oceanic island: forager patterns, density and biomass. Insectes Sociaux 52: 266–273. resources to control existing invasive species and most now focus on preventing Csurhes S, Hankamer C. 2012. Pest animal risk assessment: Yellow crazy ant Anoplolepis establishment of new invasive species. New pressures are emerging and are of gracilipes. Biosecurity Queensland, Queensland Government. high concern due to the limited resources available for control.’ Drescher J, Feldhaar H, Blüthgen N. 2011. Interspecific aggression and resource monopolization of the invasive ant Anoplolepis gracilipes in Malaysian Borneo. Biotropica 43(1): 93-99. O’Dowd D, Green P, Lake P. 2003. Invasional “meltdown” on an oceanic island. Ecology 32 State of the Environment 2011 Committee. 2011. Australia State of the Environment 2011. Letters 6: 812–817. Independent report to the Australian Government Minister for Sustainability, Environment, 34 See http://www.couriermail.com.au/news/queensland/crazy-ants-on-march-after- Water, Population and Communities. government-slashes-fighting-fund/story-e6freoof-1226518463558. . 35 See http://www.daff.qld.gov.au/30_22376.htm

ecosystem. Yellow crazy ants on Christmas Island are listed as a key threatening Suspected to be native to South-East Asia, yellow crazy ants have spread across process. the world via traded goods. They have arrived in Queensland multiple times, mostly with timber supplies, and now exist in 21 known sites, mostly near ports and timber An ‘invasional meltdown’ on Christmas Island triggered by crazy ants has resulted yards. in a “rapid, catastrophic shift in the rain forest ecosystem”, as summarised by Dennis O’Dowd and co-researchers: Although their preferred habitat is moist tropical forest they also live in the subtropics and in harsh, dry areas such as Arnhem Land. They invade horticultural In invaded areas, crazy ants extirpate the red land crab, the dominant plantations and urban areas. endemic consumer on the forest floor. In doing so, crazy ants indirectly release seedling recruitment, enhance species richness of seedlings, and The short-sighted budget-cutting will condemn future Queenslanders, including slow litter breakdown. In the forest canopy, new associations between this farmers, to much greater costs in the near future for control and eradication will invasive ant and honeydew-secreting scale accelerate and diversify become impossible unless funding is obtained in the near future. impacts. Sustained high densities of foraging ants on canopy trees result in Yellow crazy ants expose multiple failings of Australian biosecurity: high population densities of host generalist scale insects and growth of sooty moulds, leading to canopy dieback and even deaths of canopy trees. • deficient quarantine for timber imports that have allowed them to arrive and establish multiple times, Where yellow crazy ants flourish, little else does. They can remove nearly all life, leaving none for other animals, and kill small animals such as lizards, crabs • federal government lack of responsibility for quarantine breaches, and chicks. They are on the World Conservation Union’s list of ‘100 of the • World’s Worst Invasive Alien Species’. overly narrow criteria for national funding for eradication of nationally significant incursions, Queensland’s Wet Tropics World Heritage Area is at grave risk, for the ants’ preferred habitat is moist lowland tropical forest. The Wet Tropics Management • lack of transparent and objective prioritisation processes to inform funding Authority has said, ‘It would be an absolute disaster for biodiversity in our Wet decisions, 36 Tropics World Heritage Area if yellow crazy ants became established here’. They • low priority accorded to environmental threats compared to industry have recently been found in Little Mulgrave National Park near Edmonton. The threats, and Wet Tropics Management Authority received $268,000 from the Federal Government this year to search for invasive ants in the Wet Tropics, but this • the ever-prevailing short-termism. funding will now serve little purpose. Eradication programs for two other invasive ants in Queensland – red imported fire Yellow crazy ants are able to dominate large areas by forming super-colonies with ants and electric ants, which are economic, social and environmental threats – are multiple nests and multiple queens. The largest have up to 300 queens and extend nationally funded. For several years, the yellow crazy ant program has been the over several hundred hectares. They spread by budding. A mated queen leaves poverty-stricken cousin of these other programs, existing on scraps from the state her birth nest with some workers and sets up a new nest nearby. (Yellow crazy budget. National funding is restricted to species that can be totally eradicated from ants are ideal candidates for eradication because, unlike fire ants, the queens Australia, and yellow crazy ants are not eradicable from Christmas Island and the cannot fly.) The boundary of a super-colony can advance by 3 metres a day. They Northern Territory. This is a short-sighted approach for a country of such vastness don’t sting but squirt formic acid, which blinds and debilitates their prey. and ecosystem diversity.

36 See http://www.wettropics.gov.au/funding-boost-to-stamp-out-invasive-ants.html

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Appendix 3. The cost of saving the Kimberley’s wildlife small and medium sized ground-dwelling mammals such as golden-backed tree-rat (Mesembriomys macrurus), golden bandicoot (Isoodon auratus) and Monjon rock Business 101: the first step to achieving a goal is to assess its feasibility and cost. wallaby (Petrogale burbidgei), That this is often neglected for conservation goals is symptomatic of a serious grain-eating birds such as (Geophaps smithii blaauwi), gouldian deficit of intent. Take the invasive species target of Australia’s Biodiversity finch (Erythrura gouldiae)and star finch (Neochmia ruficauda), and Conservation Strategy – to reduce invasive species impacts on threatened biodiversity by 10%. There has been no feasibility assessment and no costed plan, carnivorous reptiles such as spotted tree monitor (Varanus scalaris) and rough- rendering it an aspiration destined to fail. scaled python (Morelia carinata). In contrast, a group of researchers (Josie Carwardine and colleagues) last year Without effective management, “45 species of wildlife are likely to be functionally 37 assessed the feasibility and cost of saving wildlife in the Kimberley. The optimal lost from the Kimberley in the next 20 years.” investment – sufficient to maintain 45 at-risk species over the next 20 years – The main threats are inappropriate fire regimes, feral cats, feral and domestic amounts to about $40 million a year after set up costs of $95 million. Much of it introduced herbivores (cattle, horses, donkeys), feral pigs, cane toads and weeds. would go to keeping invasive species at bay. Mining, tourism and agricultural expansion are likely to exacerbate the damage. With costs and feasibilities set out, there is now a ‘business case’ for investing in the future of Kimberley wildlife, and much less excuse for governments to avoid Investment needed doing so. Based on expert advice, Carwardine and colleagues have set out what could be The Kimberley is worth investing in achieved for different levels of investment. To keep all species across the region (with a probably of at least 90%) will cost about $40 million a year with $95 million The Kimberley is a very special region – still wild, wondrously diverse and brimming set-up costs, allocated as shown in the table. An investment of only $27 million a with unique species: year would achieve persistence probabilities of all species to at least 50%, avoiding imminent species losses but risking declines. • 65 endemic vertebrate animal species, • 309 endemic plant species, and Fire and herbivore management $25.3 million • the highest numbers of endemic invertebrates in many groups, including Weed management $2.8 million land snails. Feral cat control $2.8 million It is also special because mammals have survived there. The North Kimberley – Exclosures (for cats) $3.5 million one of five bioregions in the Kimberley – is one of only two bioregions Australia- wide to have retained all mammal species (the other is the Tiwi Islands). But this Monitoring $5 million could soon change. Annual total $39.4 million Northern Australia is facing an imminent calamitous wave of extinctions, and the Kimberley – although less affected so far than the other northern regions – is not immune. At particular risk are: The most cost-effective action is cat control but its feasibility is currently low because of the lack of broadscale control methods and the social value accorded to domestic cats. The researchers suggest that feasibility will improve with education 37 about feral cat problems and research on biocontrol and the interactions of dingos Carwardine J, O’Connor T, Legge S, Mackey B, Possingham H, Martin T. 2011. Priority and cats. However, the cat threat for at least eight mammal species is considered threat management to protect Kimberley wildlife. CSIRO Ecosystem Sciences, Brisbane.

A submission regarding the effectiveness of threatened species and ecological communities’ protection in Australia - 17 dire enough to warrant exclosure fences to create havens free of cats and possibly Appendix 4. What weeds do38 also cane toads. In the 230 years since European colonisation, Australians have imported Management of fire and introduced herbivores will deliver the greatest benefits and thousands of exotic plant species, averaging more than 100 new exotic species a are feasible although also relatively expensive. year. As a result, there are now thousands more exotic plants in the country than Weed control is ranked of lower benefit because as yet weed problems in the there are native species. More than 95% have been deliberately imported for Kimberley are not “alarming” and it is difficult to quantify the benefits of keeping out cultivation, most as garden plants and some for agriculture or forestry. By moving potential new weeds. Weed management would rate more highly for plant plants into new ranges beyond their natural dispersal barriers, and planting them in conservation, which was not considered in this study. The authors comment that numerous locations, sometimes in vast acreages, humans provide some species “an increase in funds for quarantine is likely to be a cost-effective strategy for long with advantages that allow them to establish in the wild and outcompete native term biodiversity persistence.” species. A monitoring program is essential to assess the effectiveness of management. In the short time since European colonisation – short in ecological terms – more than 3000 exotic plant species have established in the wild in Australia, and more Cats in the Kimberley than 1500 are now invading natural ecosystems. A study at Mornington Wildlife Sanctuary suggests there is a cat every 3 km², each Although weeds already dominate many ecosystems, the worst is yet to come. eating 5–12 native vertebrates daily. If this is consistent throughout the region, it Many weeds are at a relatively early stage of invasion, and many more exotic means 100,000 cats, killing at least half a million native animals daily. plants have yet to establish in the wild or become invasive. There is often a There are currently no effective control methods for feral cats – they are trap shy considerable time lag between introduction and invasion, sometimes more than a and rarely eat poisoned baits. century. The most feasible option could be to cease baiting of dingoes, which appear to suppress cat activity and kill kittens. Although dingoes are also predators, they frequently take larger prey, reducing pressure on small fauna. Relationships between cats and dingoes in the region are under investigation. One study at Wongalara Sanctuary in the Northern Territory, where half the property was baited for dingos and half left unbaited, found that cat activity decreased and small lizard populations increased in the unbaited areas. Should baiting cease, the impact on pastoralists should be manageable as only low losses are currently reported. Biological control of cats is considered technically feasible but would require a substantial change in community attitudes. Fenced cat-free areas on islands or conservation properties may be needed to save species in the short-term.

10.

38 An extract from Invasive Species Council. 2010. Stopping NSW’s Creeping Peril: A community call for action on weeds.

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A submission regarding the effectiveness of threatened species and ecological communities’ protection in Australia - 19